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The Environmental Protection Agency (EPA) and OSHA have different legal authority with respect to accidental releases of harmful substances. The concerns at EPA center on offsite consequences: that is, harm to the public and the environment. At OSHA, the legal authority pertains to on‐site consequences.

On 19 August 1996, EPA issued rule 40 CFR Part 68, Risk Management Programs for Chemical Accidental Release Prevention. Risk Management Plans required of location managements by the rule were due by 21 June 1999. Although the provisions of the rule are extensive, only the specifications for hazards analyses will be addressed here.

Processes subject to this rule are divided into three groups, labeled by EPA as Programs 1, 2, and 3. Program levels relate to the quantities and extent of exposure to toxic and flammable chemicals. For locations qualifying for Program levels 1 and 2, those with lesser exposure, EPA will accept hazard reviews done by qualified personnel using suitable checklists.

Hazard reviews must be documented and show that problems have been addressed. In its literature, EPA comments on the desirability of using the “What If” hazard identification and analysis process. EPA also proposes the use of more involved analytical techniques if findings suggest that to be desirable.

Hazard review requirement for Program level 3 locations are more specific and extensive. But those locations that are compliant with the OSHA rule for Process Safety Management of Highly Hazardous Chemicals will need to do little new, although they do need to extend their hazards analyses to consider the probability of harm to the public or to the environment. As with OSHA, a team must complete the process hazards analyses required by EPA. One member of the team, at least, is to have experience with the process.

For American industry, EPA has obviously extended knowledge and skill requirements regarding hazard analysis techniques.